- 26 -- 26 - Kennels, Inc., was incorporated, owned land, borrowed money, and did business. We sustain respondent's determination and conclude that petitioners are liable for the penalty for substantial understatement of tax under section 6662(a) for 1990. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
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